Twenty Questions
for College and University Presidents

Is your college or university in compliance? If your key
environmental expert left suddenly, would your campus be safe tomorrow?
Would you be ready for an inspection?

At the request of a number of leaders in the higher education field,
EPA, Mid-Atlantic Region, has developed the following list of questions
to help you to determine if your college or university is meeting its
legal and leadership obligations in the environmental realm. As part of
the regulated community, it is important that colleges and universities
are aware that EPA holds educational institutions to the same high environmental
compliance standards expected of private industry. In fact, EPA expects
colleges and universities to be role models for environmental behavior.

Many of the following questions relate to an Environmental Management
System, or EMS. An EMS includes such elements as policies, procedures,
tracking, and auditing. This framework helps to provide a systematic approach
to managing environmental compliance and improving environmental programs.
While having a good system doesn't guarantee compliance, if your environmental
expert suddenly leaves it greatly increases the chances that your college
or university will not falter in meeting its environmental obligations.
It does this by integrating environmental compliance activities into routine
campus operations. EMS guidance information.

Some questions to consider:

Does the school have a written policy on protecting public health
and the environment through compliance with applicable requirements
and conservation programs?

How are policy and other environmental information communicated on
a regular basis to others including campus administration, facility
management, faculty, students and their parents, alumni, and the neighboring
community?

Is there an Environmental Management System, or EMS, in place to help
the school maintain compliance and operate in an environmentally responsible
manner through policies, training, tracking, procedures, and organizational
structures that support compliance?

Does the EMS track campus operations which are covered by environmental
regulations, including state and Federal regulations?

Is the EMS updated on a regular basis to cover new, expanded or changed
operations?

Who is responsible for ensuring that each operation is in compliance
and has all the required approvals, licenses, and permits?

Do all persons responsible for and working on environmental matters
have adequate training, required certifications, resources, and authority
to perform their jobs?

Does the school's website link to EPA and other web sites that provide
access to on-line regulations, guidance, and other environmental information?

Do contracts require that all outside lessees, facility users, and
contractors are properly trained and certified and comply with all applicable
environmental regulations?

Where are documents kept such as required permits, plans, chemical
toxicity sheets and monitoring reports which can help prevent illegal
releases, address problems in a timely fashion, provide quick access
on proper handling and disposal as well as respond to questions during
inspections?
|

Are campus legal advisors familiar with EPA's Supplemental Environmental
Projects Policy, which promotes the use of environmental projects in
lieu of a portion of penalties?

Are campus legal advisors familiar with EPA's Audit Policy, which
can waive up to all penalties for self-disclosed violations that meet
the policy guidelines?

If the school conducts compliance self-audits, is there a system in
place to a. Ensure prompt correction of violations; b. Prevent future
problems; c. Elevate compliance problems immediately to campus officials?

What has been done to identify and correct environmental problems
on land formerly used as disposal sites by the college or university?

Is there a program in place to review energy consumption, use of chemicals,
and operating systems to determine how public health and environmental
impact can be reduced while operating effectively and reducing operating
costs and potential financial liability?

Is the campus participating in voluntary programs such as Energy Star
or Waste Wise and receiving national environmental recognition?

Is the school a good neighbor in helping to address area environmental
issues such as smog producing traffic, water conservation, and sprawl?

Have environmental goals been set for reducing the impact of the campus
on the environment?

Does the college or university have a system for rewarding campus
employees for environmental compliance and excellence?

Is the school a good role model for providing an education in a safe,
healthy environment?